Política de Privacidade
We (also referred to as "We", "Us", or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store information submitted through the https://alvorapossencia.com website (the Alvora Possência).
The following principles apply:
We want you to make informed decisions about how your Personal Data is used and processed. We use a range of methods to provide relevant information and, where specific details are needed, will share them at the appropriate time. We're happy to answer any questions you may have regarding applicable legal limitations.
1. O Escopo?
This policy describes the Personal Data Alvora Possência collects about individuals, and how that data is processed, shared with third parties, and protected.
This Policy applies to information relating to an identified or identifiable individual. An identifiable individual is someone who can be directly identified, or identified through a combination of additional information we hold or have access to.
"Processing" refers to any operation involving the use or collection of Personal Data, including its management, organization, and storage.
Our services are intended for a general adult audience and are not designed for use by individuals under 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we hold information relating to a minor, we will delete it as promptly as possible.
2. What Personal Data We Hold About You
When you access our Services, channels, or website, we collect Personal Data. We may request your Personal Data directly in certain situations. In others, we collect it by analyzing how you use our Services or support channels, or by receiving your information from third-party partners.
3. There is no requirement to disclose personal information to the company, nor any consequences for choosing not to do so.
Você não é obrigado a nos fornecer dados pessoais. No entanto, em determinadas circunstâncias, a falta dessas informações pode nos impedir de disponibilizar os Serviços ou de permitir o acesso ao site.
4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data from you:
This includes information about your online activity logs, traffic data (such as IP address, access date, access time, and browser type), language settings, software error logs, and the device you used. This information is non-personal and cannot be used to identify you.
Personal Data you provide to us: any personal data you voluntarily share when connecting to a third-party online trading platform through us.
Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Grounds for Processing Personal Data
Your personal data is processed by the Company for the purposes described in this section, in accordance with the applicable legal basis for each purpose.
Without a valid legal basis, the Company is not authorized to process your personal data. The legal bases on which the Company may rely to process your personal data are:
- You have provided consent for your personal data to be processed for one or more specific purposes. This applies when you submit personal information through the Site for transfer to a third-party trading platform.
- The Company or a third party may need to process data to serve legitimate interests — for example, to improve Our Services or defend legal claims.
- Processing is required to comply with a legal obligation.
Contact us by email for more details about the processing carried out to safeguard legitimate interests.
Below is a list of the purposes and legal bases we may rely on when using the Personal Data you provide to us.
Escopo, Base Legal
1. Upon your request, we may share your personal data with third parties to facilitate access to digital trading.
You have given your consent for your Personal Data to be processed for one or more specified purposes.
2. To respond to your requests, questions, or concerns. Personal Data is required to address any questions you may have about the Services.
Processing of personal data may also be necessary to serve the legitimate interests of the Company or those of third parties.
3. Personal data is processed to meet applicable legal, judicial, or administrative obligations.
Processing is required to meet legal obligations.
4. We may use your personal data to improve our Services. This includes crash reports and malfunction data collected in connection with the Services.
Processing is required to serve the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing this data is necessary to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities aligned with the requirements of Our Services. This includes back-office functions, business development activities, strategic decision-making, and oversight mechanisms.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
7. To conduct statistical and other analytical assessments, we apply a range of analytical techniques to support decision-making across various areas of our operations.
Processing is required where it serves the legitimate interests of the Company or a third party.
8.
We may process Personal Data to protect our rights, interests, and assets — or those of third parties — in accordance with applicable laws, regulations, agreements, terms, conditions, and policies, including for the purpose of establishing or defending legal claims.
Processing of personal data may be necessary to serve the legitimate interests of the Company or a third party.
6. Transferência de Dados Pessoais a Terceiros
The Company may share Personal Data with third-party service providers, including IP address hosting and storage providers, as well as platforms used for user experience analytics.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will share the Personal Data you have provided to us with those platforms. Your Personal Data will then be subject to the privacy policies of those platforms and may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to support the development and improvement of products and services offered to its customers.
Where necessary to protect the rights of third parties or assets, the Company is authorized to disclose Personal Data to regulatory, local, or other official authorities.
The Company may also share Personal Data with potential investors, acquirers, or creditors of the Company or any other entity within the group in connection with a completed transaction — including the transfer or sale of assets — or as part of any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other business within the group.
7. Cookies and Third-Party Services
We may work with third-party services, such as advertising providers and analytics companies, that operate on our site. These third parties may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit the site. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and surface products and services relevant to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies. These are downloaded temporarily to your device and expire once you close your browser. Others are persistent cookies, which remain on your device after the browser is closed. Persistent cookies help the site recognize you as a returning user and allow you to resume your session.
Tipos de Cookies:
They may be used by us based on their purpose:
1. Essential cookies only
These cookies are necessary to access the features you request and navigate our site. They enable your device to download and transmit data, allowing you to browse the site, use its features, and return to previously visited pages.
Cookies collect personal data such as your username and last login date to verify your active session. They are deleted automatically when you close your browser (session cookies).
2. Cookies de Funcionalidade
Cookies recognize you each time you visit our site and save your preferences and settings.
Cookies collect personal data such as your username and last login date to verify your session. They are deleted when you close your browser (session cookies).
3. Cookies de desempenho
We use cookies to collect statistical data on site performance and to carry out analytics that help us improve your experience.
Cookies store anonymous data not associated with any identifiable individual. Some cookies are removed when the browser is closed; others have no set expiration date.
Cookies are blocked or removed
To block or remove cookies, update your browser settings. The links below will guide you through the process for the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that disabling certain settings may cause some features or functions of the Site to not work as expected — or may affect the Site entirely.
ONLINE TRACKING NOTICE
This service does not support Do Not Track signals.
8. Retenção de dados pessoais sobre Você
We retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, policies, or orders.
Your information will be shared with third-party trading platforms for a period of 12 months. If you consent to continued sharing, we will extend this for an additional 12 months.
We regularly review the Personal Data we hold to confirm it remains necessary.
9. Transfers of personal information to a third country or international organization
Your personal data may be transferred to other countries or shared with international organizations outside your country of residence. The Company takes all necessary measures to protect your personal data and ensure users can exercise their rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area).
- Transferência para um país terceiro ou organização internacional que a Comissão Europeia determinou oferecer proteção adequada aos Dados Pessoais transferidos, nos termos do artigo 45(3) do Regulamento 2016/679 do Parlamento Europeu e do Conselho, de 27 de abril de 2016 (o "GDPR").
- A transferência é realizada ao abrigo de um acordo juridicamente vinculante e executável entre entidades ou autoridades públicas, nos termos do Artigo 46(2)(a).
- This transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information on the security measures used to protect your personal data when transferred to third countries or international organizations. To request this information, contact us at: info@alvorapossencia.com
10. Segurança de Dados Pessoais
We take appropriate organizational and technical measures to protect Personal Data, including against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without failure. We are not liable for any immaterial, incidental, or consequential damages arising from the use or disclosure of Personal Data, including Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other cause beyond our control.
Where required by legal or other obligations outside our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by such third parties.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us via the internet.
11. Links to Third-Party Websites
Links to third-party websites and applications are made available on this website. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or handle Personal Data. This Policy does not apply to actions taken through such sites or applications.
Before accessing or using any third-party site or application, we recommend reading its privacy policy carefully. Exercise caution when sharing any Personal Data with third parties.
12. Modificações nesta Política
When accessing any third-party website or application, review its privacy policy before use. Share only the personal data strictly necessary for the service.
13. Your rights regarding your personal information
You have the right to request verification of the accuracy of your Personal Data, to have any inaccuracies corrected, and to request deletion of Personal Data that is no longer necessary for our purposes. You may also restrict the scope of how your Personal Data is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to information you provide in connection with your Personal Data. To exercise any of these rights, please send a request to the email address below.
Right of Access
You may request verification of the accuracy of the Personal Data we process about you. If confirmed, you may access that Personal Data.
We will provide one electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be made available electronically upon request.
The right of access must not conflict with the rights and freedoms of third parties. Where a request would be prejudicial to another person's rights or freedoms, we may decline or limit our response.
Right to Rectification
You have the right to require inaccurate Personal Data to be corrected. You may also require incomplete Personal Data to be completed, taking into account the purpose of the processing.
Right to Erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on our legitimate interests or those of a third party, and no overriding grounds exist; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to fulfil a legal obligation.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defence of legal claims.
Restriction of Processing
If you question the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, for the protection of another individual's rights, or for reasons of substantial public interest within the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and based on consent or a contract to which you are party, you have the right to review the Personal Data you have provided to us.
You may request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure, nor does it interfere with the rights or freedoms of third parties.
Right to Object
You may object at any time to the processing of your Personal Data based on our legitimate interests or those of a third party, including profiling based solely on those interests. Where we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to process the data.
With respect to direct marketing, you may object at any time to the processing of your Personal Data for that purpose.
Right to Withdraw Consent
You may withdraw consent to the processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that withdrawal.
You have the right to lodge a complaint with the competent supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect individuals' fundamental rights with regard to the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights with respect to your Personal Data as detailed in this Section 13.
We will respond to requests submitted under the rights set out in Section 13 within one month of receipt. Where necessary, this period may be extended by up to two months depending on the complexity and volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons for the extension.
Subject to the provisions of Section 13, information provided in response to the exercise of your rights will be supplied free of charge. Where requests are manifestly unfounded or excessive, in particular due to their repetitive nature, we may charge a reasonable fee to cover the administrative costs of providing the information or communicating the requested action, or we may decline to act.
Where we have reasonable doubt as to the identity of the person submitting a request, we may ask for additional information to confirm identity.